ML19340D243

Forwards Revised 10CFR50.48 & App R to 10CFR50 Re Five Protection Features of Nuclear Power Plants.Rules Take Effect 810217.Summary Listing of Open Items Re Fire Protection Features of Facility Encl

ML19340D243
Person / Time
Site:	Millstone
Issue date:	11/24/1980
From:	Eisenhut D Office of Nuclear Reactor Regulation
To:	NORTHEAST NUCLEAR ENERGY CO.
References
TAC-48143, TAC-52156, NUDOCS 8012290415
Download: ML19340D243 (22)

Text

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"" * %y UNITED STATES j } ;,[\\

g NUCLEAR REGULATORY COMMISSION

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Novenber 24, 1980 r gl

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1)yht i, ~ m(( Q3{,]j Docket No.

50-336 m

Plant Name: Millstone Nuclear Power Station, Unit 2 l

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TO ALL POWER REACTOR LICENSEES WITH PLANTS E

M LICENSED PRIOR TO JANUARY 1,1979 "y

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2 The Comission published on November 19,1980 (45 FR 76602), a revised Section 10 CFR 50.48 and a new Appendix R to 10 CFR 50 regarding fire protection features of nuclear power plants.

The revised Section 50.48 and Appendix R will become effective February 17, 1981, which is 90 days after publication.

A copy of the Federal Register Notice is enclosed (Enclosure 1).

The provisions cf Appendix R that are applicable to the fire protection features of your f acility can be divided into two categories. The first category consists of those provisions of the Appendix that are required to be backfit in their entirety by the new rule, regardless of whether or not alternatives to the speciHe requirements of these Sections have been previously approved by the NR'

'. These requirements are set forth in Sections III.G, Fire Prots af Safe Shutdown Capability; III-J, Emergency Lighting; and III-0, 011 Collection Systems for Reactor Coolant Pump. The fire protection features of your f acility must satisfy the specific requirements of these three Sections by the dates established by Paragraph 50.48(c), unless an exe@ tion from the Appendix R requirements is approved by the Commission. You should note the provisions for tolling the time for co@leting the modifications required by these three Sections of Appendix R set forth in Paragraph 50.48(c)(6).

The second category of Appendix R provisions applicable to the fire protection features of your f acility consists of requirements concerning the "open" items of previous NRC staff fire protection reviews of your facility. An open item is defined as a fire protection feature that has not been previously approved by the NRC staff as satisfying the provisions of Appendix A to Branch Technical Position BTP PCSB 9.5-1, as reflected in 'a staff fire protection safety evaluation report.

The fire protection features of your f acility that are in this category must satisfy the specific requirements of Appendix R by the dates established by Paragraph 50.48(c), unless an exemp-tion from the Appendix R requirements on those-features is approved by the Comi ssion.

Enclosum 2 is a summary listing of the open items concerning the fire Also protection features of your facility based on a review of our records.

included is our position on the specific requirements that nust be satisfied in order to resolve these open items.

If you have any questions or disagree-ments with this enclosure, please advise us within 30 days of your receipt of this letter.

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2 With regard to the fire protection modifications that have been previously approved by the NRC staff, Paragraph 50.48(d) specifies a new schedule for their conpletion.

This paragraph, when it becomes effective, will supersede the currently effective section of the regulations that tenporarily suspenas conpletion dates for previously approved fire pruf.ection modifications that are given in facility license conditions (45 FR il569, October 29,1980).

The Conmission expects that all such modifications will be conpleted in accordance with this new schedule, unless an extension has been requested and granted by the Director of the Office of Nuclear Reactor Regulation

[see Paragraph 50.48(d)], or an exenption has been requested and granted by the Conmission pursuant to Section 50.12 of the Consnission's regulations.

If you have previously requested extensions of datas for conpletion of modifications that are required by license conditions for your facility which were not approved, and you have determined that these extensions are still necessary and justifiable, it will be necessary for you to reapply for any such extensions 'in accordance with the provisions of Paragraph 50.48(d).

All requests for Coninission action resulting from this rule are subject to the schedule of fees specified in 10 CFR 170.21.

If you have any questions concerning the subject matters of this letter, please contact the NRC Project Manager for your facility.

Sincerely.

'O

[ xuameu Darrell G. Eisenhut Director Division of Licensing Office of Nuclear Reactor Regulation

Enclosures:

1.

Notice - Fire Protection Rule 2.

Summary of Staff Require-ments to Resolve Open items cc w/ enclosures:

See next page

Northeast Nuclear Energy Company Cc:

William H. Cuddy, Esquire Mr. John Shediosky Day, Berry & Howard Resident Inspector / Millstone i

Counselors at Law c/o U.S. NRC One Constitution Plaza P. O. Drawer KK Hartford, Connecticut 06103 Niantic, CT 06357 Anthony Z. Roisman Mr. Charles B. Brinkman Natural Resources Defense Council Manager - Washington Nuclear 917 15th Street, N.W.

Cjp t$hstems Washington, D.C.

20005 er k "'"

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j Mr. Lawrence Bettencourt. First Selectman j

Bethesda, Maryland 20014 H

of cord - 200 Boston Post Road Waterford, Connecticut 063B5 Northeast Nuclear Energy Company ATTN:

Superintendent Millstone Plant Post Office Box 128 Connecticut Ener A

Waterford, Connecticut 06385

. ATTN:

Assistant ire to, Research and Policy Development Director, Criteria and Standards Di. vision Department of Planning and Energy Policy Office of Radiation Programs (ANR-460) 20 Grand Street U.S. Envirorhental Protection Agency Hartford, Connecticut 06106 Washington, D.C.

20460 U. S. Environmental Protection Agency Region 1 Office ATTN:

EIS COORDINATOR John F. Kenr.edy Federal Building Boston, Massachusetts 02203 Waterford Public Library Rope Ferry Road, Route 156 Waterford, Connecticut 06385 Northeast Utilities Service Company ATTH: Mr. James R. Himmelwright Nuclear Engineering and Operations P. O. Box 270 Hartford, Connecticut 06101 9

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i Eo*!."E'"19,1980 i

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l Part 11 Nuclear Regulatory Commission Fire Protection Program for Operating Nuclear Power Plants l

76602 Federal Register / Vol. 45. No 225 / Wednesday November 19.1980 / Rules and Regulattor.s*

NUCLEAR REGULATORY fnat tae comment periou snauld ne e ata airea.ly set iottn in Genera; Design COMMISSION tieen extended-Catermn 3 of Appendia A to 10 CFR The Commission does not agree The Nrt 50 and m the NRC guidance 10 CFR Par 150 NRC has been develnpmg fire protectmn dxuments These general provisions requirements since 1975 The NRC me rue to a number of disputes oser Fire Protection Program for Operating pubbshed comprehensive fire protectmn whether spenfic methods adequately Nuclear Power Plants guidehnes, Branch Technical Position accompinhed the intended goal.He Gotwcy: Nuclear Regulators BTP APCSB 9 5-1. and its Appendix A in pr > posed rule is mtended to provide Commisuon.

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19m Licensees hase compared their fire sufficient specific guidance to ensure Action: Fmal rule.

pr tection programs agamst these satisfactory resolution of these issues.

guidehnes and have discussed their Thus. res erting to generabzed guidance suesesany: The Nuclear Regulatory deviations from these guidelmes with would not accomplish the mtended 1

Commission is amending its regulations the NRC staff for the past four years purpose of the proposed rule.

to require certain provisions for fire dunng the NRC's fire protection reviews The second issue involved some protection in operating nuclear power of operating reactors. A Safety instances in which the specific wording plants. This action is being taken to Evaluation Report and. in most cases.

used resulted m unnecessary and upgrade fire protection at nuclear power - supplements to the Safety Evaluation unintended restrictions. For example, plants licensed to operate pnor to Report. have been issued for each the proposed rule called for a " fresh January 1.1979. by requiring resolution operating reactor. These reports water" supply. For firefighting purposes.

i of certain contested generic issues in descnbe fire protection alternatives that brackish water is satisfactory and a j

fire protection safety evaluation reports. hase been proposed by the hcensee and

" fresh" water supply is unnecessary.

EFFECTIVE DATE: February 19.1981.

found acceptable by the staff as well as Similarly. the proposed rule called for Note.-The Nuclear Regulatory unresolved fire protection issues an " underground" yard fire main loop.

Commission has submitted this rule to remaining between the staff and the Of ten portions of a fire mam loop run the Comptroller General for review as licensee. Proposed Appendix R provided abose ground in and as they enter structures.The Commission had not may be appropriate under the Federal the Commission's requirements for Reports Act. as amended (44 U.S.C.

resolving thowe issues. Thus. It concerns intended to prohibit running portions of 35121.The date on which the reporting only a limited number of issues derised a fire main loop above ground. Other requirement of this rule becomes from the use of the earlier guides. The sinilar changea are discussed in Section effective, unless advised to the centrary. Commission believes that a 30-day 111. " Specific Requirements." of this reflects inclusion of the 45-day period comment penod was adequate under preamble.

The third issue relates to,mposition of i

that statute allows for such review (44 these circumstances.

requirements on plants with presently U S C. 3512(c)(2]).

2.Many licensees questioned the need installed or with existing commitments Fon FunTwan weronesarion coerf acT:

for backfitting all the requirements of t install fire pr tecti n features David P. Notley. Office of Standards Appendix R.They commented that they previ usly determined by the staff to Development. U.S. Nuclear Regulatory had previously complied with staff fire satisfy the guidance of Appendix A to Commission. Washington. D.C. 20555, protection recommendations in " good D TP APCSD 9.5-1. The Commission i

phone 301-443-5921 or Robert L faith" and have committed to or grees a cbtt d Ferguson. Office of Nuclear Reactor completed certain modifications. They 8'bo ha

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Regulation. U.S. Nuclear Regulatory contend that the staff has properly Appendix R should not be retroactively Commission. Washmgton D.C. 20555, determined that these modifications appl ed to features that have been phone 301-492-7046.

provide at least the level of fire previously approved by the NRC staff as supos.aasawTAny peronesarioN: On May protection descnbed by the guidance

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,ig the provisions of Appendix A y

29,19H0. the Nuclear Regulatory contamedin Appendix A to Branch to BTP ApCSB 9.5-1.

i Commission published in the Federal Technical Position BTP APCSD 9.5-1.

The NRC staff had intended. in its Register (45 FR 36082) a notice of They also contend that these original proposal for Appendix R. that proposed rulemaking inviting written modifications provide a level of the requirements be applicable only for suggestions or comments on the protection at least equivalent to that the resolution of unresolved disputed proposed rule by June 30.1980. The contained in the proposed rule.They fire protection features. Thus, the staff notice concerned proposed amendments express the concern that the proposed had not intended the provisions of to 10 CFR Part 50. " Domestic Licensing rule was written in such specific Appendix R to seguire modification of of Production and Utilization Facilities."

language that fire protection issues that previously approved features. This was i

which would require certain minimum were thought closed would be reopened not clearly described in the proposed I

provisions for fire protection in nuclear and new but not necessarily better, rule as pubbshed for comment. In fact.

power plants operating prior to January modifications would be required. These the Supplementary Information 1.1979 Fifty-one comment letters were modifications could be accomplished published with the proposed arule received regarding the proposed only by the expenditure of considerable explicitly indicated that "[alll licensees amendments. A number of comments engineering, design. and construction will be expected to meet the pertained to specific requirements in the effort and at great undue expense. The requirements of this rule,in its effective propcsed Appendix R. and these will be commenters request that the form. including whatever changes result dealt with below. Ilowever, there were requirements in the proposed rule be from public comments."

three substantive contentions which rewritten to specify only the general in determining whether the specific were raised by many of the commenters requirements of what needs to be requirements of Appendtx R should be These three commna are summarized accomplished.

imposed on hcensees with presently as follows; These comments raise three related installed or existing commitments to

1. Most commenters stated that the 30 issues. The first relates to the need for install fire protection features previously day comment period was too short to specific requirements. The general determined to sa6fy Appendix A to permit adequate detaded response and requirements relating to fire protection Branch Techma.: Position DTP APCSB l

e-Federal Register Vol 45 No. 225 / Wednesdas. November 19. 1980 / Rules and Regulations 76603 o'

1 ap%nt to re: emze that arrangerntn's were accepted in some permitted either an od collection spiem Appewa R a.! dresses crd) a portion cf early fire protection renews As a result er a fire suppression s> stem The staff er *pecta nems contmned n the more of some separate effects tests. the staff has also accepted an automatic fire s apn+enme document. Branch chanced as posinon on this suppression system as an acceptable To r %.d Nsmon BTP APCSB 9 5-t confwuratwn. and subsequent pians method of fire protectmn for this and as Appendn A Appenda A to BrP ha e been required to proude apphcation. The Commission has APCsH 9 %1 hn been the bu.c fire additional protection in the fcrm of fire concluded that fire suppression systems prmec vn udanu used by the stalf m barners or substantial physical do not gne adequate protection for fires they f re protection renews conduc:ed separatwn for safe shutdown systems that may be mduced by seismic esents.

f"r 4 eperanna plar.ts durmg the past No credit for such coatings as fire The Commission therefore beheses that m era! y ears. For many plants.

barriers is allowed by Section !!! G of previously approved suppression incrsces preposed 33 s' ems and features Appenda R Appenda A to Branch systems should be replaced with od t.%t satafactanly achiesed the fire Technic.d Position BTP APCSB 9.51 and cellection systems that can withstand protect cn cntena set forth m Appenda the proposed Appendix R recognized seismic events.

A m BTP APCSB 9 5-1 and began to that there were plant unique The technical bass on which these prompt irnp'ement such features and configuratmns that required fire three sections are based are further wems protection features that are not identical discussed in Section 111. " Specific Samfattoit features and systems are to those listed in Section 111 G of Requirements." of this preamble.

alreads m p!he and m operation it.

Appenda R. For these cases. fire

3. Most commenters stated that the m ny p; ants There is a reasonable protection features were developed by implementation schedule contained in scree of uniformits among most of the hcensee and described in a fire -

the proposed rule is impossible to meet these arroned features for all facdities hazards analysis Some of these for any of the operatmg plants. The smce thm were reuewed asamst the arrangements were accepted by the staff commenters further stated that if the Yena of Appenda A to BTU as prosidmg equivalent protection to the impien entation schedule in the effective me APGD 9.b; In general. the features requirements of Section !!!.G to rule is the same as that m the proposed prmioelv approsed by the NRC staff m Appenda R.

r ule. the Commission must be prepared its reums of hre protection usms the Requirements that account for all of to either shutdown each operating t rena of Appnda A to BTP APCSB the parameters that are important to f;re nudear power plant or process 9 5-t pnnide an eqmvalent lesel of fire protection and consistent with safety exemptmn requests.

The commenters then concluded that pmternnn safety to that provided under requirements for all plant-unique the geafie provisions of Appcndix R configurations have not been developed. the implementation schedule should be rewritten to allow an adequate time Thut the f urther beneht that might be In hght of the experience gained in fire pnaided bs reouinne that preuously protection evaluations os er the past four pri d for compliance. The proposed rule sta:ed that "all fire protection and appresed features be modified to years. the Commission beheves that the modifications identified by the staff as mnfr.rm ta the specific language set hcensees should reexamine those necessary to satisfy Criterion 3 of forth m Appenda R a outweighed by presiously approved configurations of Appendix A to this part. whether the ou tal! benefit of the early fire protection that do not meet the

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c ntained m Appendix R to this part or impbmentatmn of such preuously requirements as specified in Section in ther staff fire protection guidance appros ed features. which in many cases

!!!.G to Appenda R. Based on this I[*CP are cu*rently bemg mstalled.

reexamination the licensee must either

,,td ca 1 ty) sha e mpleted erthelest as a result ofits meet the requirements of Section !!! G of by November 1.1980 unless. for good contmame reuew of fire protection Appendix R or apply for an exemption cause shown the Commission approves manert the NRC staff has mdicated to that justifies alternatives by a fire a Mmiom" (proposed paragraph the Commaston that there are hazard analysis. However, based on 50.481.(c)). The Commission went on to reywrernents m three sections in which present information. the Commission state its intention in the Statement of the pro'ectmn afforded by Appendix R does not expec* to be able to approve Consideration to the rule that "

.no oser and above that preuously exemptions for fire retardant coatings plant would be allowed to continue to au ep'ed. mav be desirable. The used as fire barners.

operate after November 1.1980. or Comwston has decided that these The second relates to emergency beyond an extended date approved by reymremen's should be retroactnely hghtmg. Section !!!.] of Appendix R calls the Comission. unless all modifications apphed to all facihties. This decision is for 8-hour emergency lighting, whereas (except for alternate or dedicated not meant to reDett adversely on in some cases less than 8-hour shutdown capability) have been prevmus htensee or staff evaluationt emergency hshting has been accepted as implementedJ rather ss purpose is to take fully into satisfying Appendix A to BTP APCSB The Commission has reconsidered the account the mcreased knowledge and 9 S-1. W hde an adequate level of safety implementation schedule and has espenence deseloped on fire protection may be provided by less than an 8-hour determined that it should be modified matters oser the last several years supply, an 8-hour system would provide for the following reasonsn The I rst of these sections is related to added protection and would generally

• After reviewing the comments and fire protectmn features for ensunna that involve only a small cost The the information developed as a result of sy stems and associated circuits used to Commission therefore believes that completion of fire reviews over the past achiese and maintam safe shutdown are licensees should upgrade the previously 6 months, the staff has informed the free frem f:re damage. Appenda A to approved facilities to satisfy the 8-hour Commission that the date of November DTp ApCSD 9 51 permits a combination hghting requirement of Appendix R.

1.1980. is not possible because the of fire retardant co.itmgs and fire The third relates to protection against effectise date of the rule wdl be after detection and supressmn systems fires m noninerted containments that date.

whout <pecify mg a phy sical se;>aration involving teactor coolant pump

• The staff has informed the datance to proteumn redundant lubricatan cd (Sectmn 111.0 of Commission that it wodd expect sy sterns ( Appendix A. D.1(2)) and such Appendix Rl. The proposed rule virtually alllicensees to request

s 766M Federal Register / Vol. 45. No. 225 / Wednesday. November 19. 1980 / Rules and Regulations esemptmns if the new implementation Section III. we provide a summary of the automatic water suppression system dates do not provide an appropriate Techmcal Basis for each requirement, throughout the plant.

period of time for complying with the followed by a summary of the public An ensured minimum volume of water requirements of Appendix R. The time comments and a statement of the staff's is set aside and dedicated for fire and manpower resources needed by the dispositmn of those comments.

protection uses to be avad.ble at all U**

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licensees to prepare such requests and Section 1 /otraint twn and Scope water uses in the plant. 'I his water by the staff to formulate trcommendations on these rerpests is This section has been revised as a volume is dedicated for fire seruce by not warranted from the standpomt of result of comments to include a means of separate storage tanks or timely fire proter tion improvement.

discussion of the importance of safe separate pump suctions from a large

• The revised implementation shutdown capability and the disti iction body of water. When common tankage schedule provides a careful balance of between requirements for " safety-is employed for fire service needs and these considerations. calhng for the related" equipment and equipment other water services. the fire pump remam:ng fue protection modifications ne:ded for " safe shutdown."

suctions must be at the bottom of the tank and other water supply suctions to be implemented and insi.J!ed on a Section //. Generel Requirements phased schedule that is as prompt as must be located at a higher level to can be reasonably achieved.

This section has been substantially ensure that the minimum dedicated The revised schedules distinguish rewntten as a result of comments to water volume is set aside for fire between requirements imposed for the provide a concise summary of general protection needs. Administrative first time on the hcensee by Appendix R requirements. The specific requirements controls by themselves, such as locked and those requirements already imposed were consohdated with the appropriate valves to ensure edequate water supply in license conditions or Technical parts of Section III. " Specific for fire fighting needs, are deemed Specifications issued prior to the Requirements." except that the credit unacceptable at nuclear power plants.

effective date of the nde. For given for 50 foot separation has been Comment Resolution requirements imposed by Appendix R.

dropped.

Many conimenters stated tha: we includmg the items "backfit" to all Section ///. Specific Requirements were being too restrictive by e.jpulating plants, the nhedule provides a reasonable time after publication of the The requirements in this rule are an underground yard fire main loop and rule for completion of required based upon pnncipies long accepted freih wa. a.molics. Our intent was modifications. For requirements already within that portion of American industry only that a yard fire main loop be imposed by license conditions providmg that has been classified by their furnished. We have deleted the for implemention after November 1.

insurance carriers as " improved Risk" specification for an underground loop 19a0, the Cornmission has reviewed or "flighly Protected Risk". In each of since special conditions may dictate that these schedules and has found that in these cases. the Commission has part of the loop be above ground or some mstances the allotted time for decided that the overall interest of inside safety-related buildings. Such completion of the required modifications public safety is best served by arrangements are acceptable.

may be excessive. Thus. for fire establishing some conservative level of With regard to the specification for a protection features other than those fire protection and ensuring that level of fresh water supply, the staff was covered by Appendix R. although the compliance exists at all plants. The attemptirig to avoid potential plant Commission has extended the following is a list of the specific problems that are not associated with compliance dates beyond the November technical bases and resolution of public fire protection. From a fire protection 1.1980, date in the proposed rule, the comments for each of the specific standpoint, salt or brackish water is Commission has added a requirement requirements in Appenda R.

acceptable for fire suppression provided that limits the compliance schedule in A. Water Supplies for Fire the fire protection system is designed existing licenses if such schedules Suppression Systems Technica/ Basis.

and maintained for salt or brackish extend beyond what we now beheve One of the basic fire protection water. The requirement for fresh water should have been a reasonable schedule requirements for a modern industrisl supplies is therefore dropped. Other initially. Rehef from such limitation may site in the United States is a separate operational problems unrelated to fire be granted by the Director of Nuclear water distribution system for fire protection that may result from the use Reactor Regulation upon a showing that protection with dual water supplies.

of s alt or brackish water for fire there is good cause for extending such Duplicate water supplies are required 'o suppression activities are outside the date and that pubhc health and safety is ensure uninterrupted fire suppression scope of this regulation.

not adversely affected by such capabuity allowing for single failures Several commenters took issue with extension.

and periodic maintenance and repab of the requirement for two separate It should also be noted that for vital portions of the systems. Duplicate redundant suctions, stating that some licensees whose hcense conditions water supphes may consist of neparate plais use a single large intake struc: tre imposed a schedule with a comphance suctions for fire pumps from a large on a lake or a river for all water date of November 1.1980, or other date body of water such as lake, river, or requiren.ents. The requirement for prior to the effective date of i 50.48 the pond or from two water storage tanks.

separate intake structures was not Commission has suspended such For nuclear power plants. the intended and the rule has been clarified.

compliance dates by promulgating on distribution system is required to consist Several comments called for deleting October 29.1M. a temporary rule of a loop around the plant with suitable the require.ments for dedicated tanks or i 50.48 (45 FH 715691 which will be valves for isolating portions of the use of vertical standpipe for other water supersed-d by this rule.

system for maintenance or repair services when storage tanks are used for To better unders.and the nature of the without imerrupting the water supply to combined service-water / fire-water uses, public comments reueived and the staff's the various fire suppression systems in on the basis that this is overly restrictive resolution of these comments the the plant.Thus, with dual supplies and a and other ways are available to ensure followmg section will consrJer each loop concept. an adequate water supply a dedicated supply such as weirs, section of Append.x H to this part. In can be ensured to each manual or suction location, etc. Two separate but

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Fed'eral Register / Vol. 45. No. 225 / Wedr:esday, November 19, 1980 / Rules and Regulations 76605 related issues are involved here. The hour water supp!> is considered by a visuall> indicatmg nr key. operated first is the requirement for dedicated adequate. it should also be noted that (curb) vah eJ' and there was an 4

water storage tanks for fire fighting this minimum dedicated water volume is opportumty to comment on this 1

purposes The suggestion that the based on maximum flow rates. Since

document, requirement for dedicated tanks be most firen are controlled and D. Manual Are Suppression Techmco/

deleted was rejected for the reasons extinguished with much smaller flow Basis. Considerable reliance is placed stated in the precedmg Technical Basis.

rates this requirement realistically on automatic fire suppression systems The other point desis with ensuring represents a dedicated water volume far throughout a nuclear power plant.

minimum water storage capacity for fire in excess of two hours-However, manual fire fightmg actnities suppression activities when eterage B.Sectiono// solation Valves.

often can control and extmguish slowly tanks are used for combined service.

C. Hydrant / solation Valves developing fires before an automatic fire water / fire-water uses. The term TechmcolBasis. These two suppression system is actuated. In

" vertical standpipe for other water requirements are similar and can be addition, fires that are controlled or i

service" simply means that the suction treated together. Proper valving is extinguished by automatic systems for other water uses in common storage required to isolate portions of the water require a certain amount of manual

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tanks will be located sufficiently high to distribution system for maintenance or response. Also, some areas of the plant ensure the minimum water volume repair without interrupting the water do not warrant the installation of naade for fire suppression activities. If supply to manual or automatic fire automatic fire suppression systems.

the commenters were assuming that suppression systems inside the plant-Manual response is the only fire

" vertical standpipe" referred only to Valves are similarly required to permit suppression available for these areas:

pfpes inside the tank, this is not the isolation of outside yard hydrants from thus, it is important that manual fire case. In fact a standpipe exterior to the the water distribution system for fighting capability be present in all stcrage tank is more desirable since any maintenance or repair without areas of the plant, and that standpipe leakage would be immediately evident, interrupting water supply to fire and hose stations be located throughout On an internal standpipe a leak in the suppression systems inside the plant.

the plant. The standpipe and hose pipe could ectually allow depletion of Visually indicating valves such as post stations are to be located so that at least 1

the water otherwise to be reserved for indicator valves are preferred so that one effective hose stream can be e can be adily brought to bear at any location in the fire uses. The rule has been clarified to po'i the 7,a

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d plant c ntaining or presenting a hazard allow physical alternatives for water yg g, km u M sup ly dedication but to preclude to structurn, systems, or compomnts exc unive use of administrative controls valves) are acceptable for these imp rtant to safety.They are to be for this purpose' purposes where plant. specific supplied r m the fire water supply conditions warrant their use.

Some commenters objected to the B. Section Control Valves--Comment system except for those inside l

requirement that other water systems Resolution. Many commenters stated containment, which :nay be connected t ther reliable water supplies if a used as a backup water supply for fire that the requirement for " approved protection should be permanently visually indicating" sectional control 8eparate penetration into containment f

cannot be made for fire water service connected to the fire main system and valves was overly restrictive, needs.

suggested that it would be sufflctent to unnecessary, and not specific with provide a water supp!y capable of being respect to who should give the approval. Comment Resolution connected to the fire main system within The Commission has accepted this suggestforu the rule now requires that Several commenters suggested adding ten minutes of the loss of normal water supply or pumps. The rule does not sectional control valves shall be a sentence reading " Standpipe and hose address backup water supplies. The prcvided to isolate portions of the fire stations are not required if sufficient requirement means that,if another main for maintenance or repair without justification can be provided that water system is used as one of the shutting off the entire system. Post adequate fire protection features have redundant water supplies. it must satisfy indicator or key-operated valves are been provided to account for a given fire all of the requirements of the fire mentioned as two examples of area." This suggestion was rejected. The protection water supplies. Additional acceptable valves.

staff has taken the position that the backup supplies need not meet these C.HydrontBlock Valves-Comment minimum requirements are that at least requirements.

Resolution. A number of commenters one effective hose stream that will be One commenter asked why only a made suggestions for rewording this able to reach any location that contains two-hour water supply is required when section. This section has been clarified or could present an exposure fire hazard the Browns Ferry Fire lasted well over to state the requirement for capability to to the safety-related equipment.The two hours. All of the investigations of isolate hydrants from the fire main Commission concluded that no analyses the Browns Ferry Fire clearly show that without disrupting the water supply to can identify hazards so carefully that if water had been used immediately, the automatic or manual fire suppression this minimum requirement can be fire would have been extinguished much systems in any area containing or further reducd earlier. Indeed once the manual fire presenting a fire hazard to safety-related E. Hydrostatic Hose Test Technical fighting activities were started with the or safe shutdown equipment.

Basis. Fire hoses should be use of only one fire hose stream. the fire One commenter suggested that this hydrostatically tested periodically to was extinguished within one half hour.

requirement be dropped in its entirety ensure that they will not rupture during The staff would fmd unacceptable any since it "is a new requirement which has use. The requirement for a minimum test condition in which a postulated fire that not been subjected to the peer review pressure of 300 psi comes from NFPA could threaten safe shutdown capability process." This suggestion was rejected No.196 (National Fire Protection could not be controlled and extinguished on the basis that Appendix A to BTP Association Standard No.196-within two hours with any combination APCSB 9.5-1 contains the following Standard for Fire Hose), a nationally cf manual and automatic fire sentence: "The lateral to each hydrant recognized consensus standard. This suppression activities. Therefore a two-from the yard main should be controlled standard contains other guidance for the e

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~6606 l'ederal Register Li n No. D Ednesday. Es ember lo 14i Ru? and Regulations e i,, ' W to e

.s u ster.n J v t cius h M be Ito /P _ &/r tre Te< hnu n, o

atuur,,f*! wfd retamed The fm kirs anah sis - w W' md. a mdastnal pLmts

'"N I"' " "Pd"" '"w ew on 'c hn w e wpto e M t est s alues

' /rst unor Ce but this would be m addit:on to 'he f a" approm ha the*e of a modern nuclear Mans c ommemers po M. J me mertum 9 stee p<m. red W r tu generating station base a f Stime fu;h equipped fire erroneu usw. of the 'm sen h.

g p;.g.,

,;c c M 9W n pressure ' rmher th. n ' opene q,gg,,, g j, agm g 4,petment. monJmg nwtonzet' fire preswre m this requirement lb"

$ectne for the potei tion of safe a;'pa'atus bhaudof 'he redu(ed m! ended meanma for this requucment is shutdown tapabihty is to ensure that at seserm of bre hazards.n a noch ar

' hot all hows wou!d be tested at a irast ce means of ai hieung and generatmg station as compcred to a pressure creater than the maumum mamtamms safe shutdown cond.tions manufacturing plant tFe Comm:ssion pressure f ound in the f:re pro'ection mp, n.mmn as adaue dunng and alter beheses that it is not nec essary to w ater astribution systr ms. T he corn 7ct ans postulated fire m the plant Because nundate a fully staffed fire department termmohm is "operatmu pressure lh"

t a not possible to predict the specific llowes er. manual fire response rule has be< n so thanced in addition-u nditions under which bres ma) occur capabdity is requred at a nudear plant the wfl added a spenfic mmm a,a test and propagate. the des:gn ham and a proper 4 equipped and fuHy pressure reqmrrment of mn psi to meet pob r N Wures e c c hd @>r mmed Cre brwde mU utsfy this the A PA standard than the des >gn basis fire Three need The Commission has determined One i ommenter also pointed out that ddferent means for prots enna the safe that a brigade of fise persons constitutes hoses should be mspec ted for mddew.

Ohn@hWded the m:mmum size sufficient to perform contamment are aci eptable The first Se actums that may be required by the rot cuts. or other damace Although this e

@ M iMmW g Wufe enu tb fire d to pWe is a s ahd c omment. it is not an unresob ed issue with any brensee so it shutdown trams and assocuted arcuits

$"me margm for unanticipated events.'

need not be cos ered by this rule. In In means of 3-hour fire rated barners N'va4 the trummg requirements addition. such inspections are already h-ond m m n a w h e n d hsted are considered the mmimum needed to ensure that the fire brigade bems p7rturmed in accordaru e with the undW h d &&u plant s i er hmcal Specif!cattons trams and associated circuits b3 a 1

"'d h" ab'e to function effectively F Mmatw hre Detectwn t.en,,nwu!

hout h.re rated barner and automata firr t3unng a (in emergency The pmposed ruk %nrrd emergency Hasa l he requirement that automatic'll suppression and detection capabihty for fire detection s3 stems be mstalled in a taca. fung apparatus without spedf>mg both redundant trams. The third means' the number af such pieces of apparatus.

a. reas that contain safe shutdown or d4h The rub has been modifmd to sPccifF safety related systems or components redundant trams and assoc.ated circuits foilow s genera!!y accepted fire the personnel for w hom such apparatus protecnon practire. Installatmn of such is to be provided and to specify reserve sp.n.e, requnes autamatic fire fire detertion capabihty is mdependent suppresmon and detectwn systems in R Ne Brigade-Comment of any requirements for automatic or the area. An alternme or dedicated manual fire suppressian capabdity in an ggg area The purpose of these detection safe shutdown capahdity mdependent of changmg this redirement to a simple systems is to gne early warmng of fire the fire area is required if nie protection statement that a trained and equipped' conditions in an area so that the hre for safe shutdowr capablity carinot be g

gg ggg provided as outimed above, f or cables persons be provided on each shift unless brigade can imtiaic prompt actions to mimmire fire damage withm the plant.

and equipment needed for safe a 1 sser number is justified. This shutdown located mside of namnerted rec omnwnded change was rejected by Comment Resolution contamments. a lesser degree of fire the Commission for the reasons stated Many commenters suggested that the protection is permitted because m the Technical basis.

I words " automatic fire detection transient exposure fires are less h.,

iy Me commenters objected to the ae q.apa bih t3 he substituted for mside containment durme plant eulusion of the shift supervisor from automatic fire detection sy stems" on operation Sectmn Ill.M. bre Nrra rs..

the bre bngade. The commenters felt the basis that as worded. the discusses the technical basis for the 3' that the shift superusor should go to the requirements are too hmitmg. fhey hour barner, and Section !!!L hre and proside the benefit of his stated that an automauc sprinkler Alternative and Dedicated Shutdown nperuse and authonto The rule would s3 stem with appropnate.darm r heck Lapab:hty. discusses the technical y,t praent this llowher the shift vahes and < entral alarm featgres basis for safe shutdown capabihty-mgervisor may he.. m go elsew here proudes aucptable detection; alarmma Ceem hnen durma the tourse of a fire that adversely l

( apa bih t) Sacral commenters daimed affects plant operaticn.The fire brigade that a separate detutmn 3ptem is not Many commente,s suggested that th" b>ader must stay with the fire brigade needed m areas omcred by spnnkler first paragraph be changed shahtly and and be assigned no other system equipped with fusible hni the rest of this section deleted Th" responsihihties darmg a fire emergency, spnnkler ht adt A fuuble hnk has a basis for their contention is that the rule therefore. the shift supervisor must be time delay before it attuates floweser.

should state simply the rquirement to exhided from membership on the fire more importantiv, a smoldering protect cables or equipment m systems brigade.

locahzed bre that could do damage ma3 necessary for safe shutdown of in = phmt L Dre Bmade 7~romimt-Comment not ge ne ate enough heat to melt the and lease specinc implementation gnojegy.' Mans commenters have fumble hnk While we do not disagree details in some other type of document.

that the alann f rorn an automatic fire We have modified this section by

% n h.a, w m ihe wc si.fr.

suppression s3 stem serses a3 remoung the listing of considerations.

Nk.en of M.mm im nre imple sNn ss.

notificatmn that a fire custs, we deletmg Table L and reusmg the W W mm %-m.m imm %d concluded that the mirumum wording to proude clarification.

($$

' Q '"7 N [ "[,",}c requirement for a separate fire detection IL Fire Brixade ya

I

{

Federal Register / Vol. 45. No. 225 / Wednesday, November 19. 1980 / Rules and Regulations 76607 s!.i b. v NRL aed unnecessary detan fire emergt rq.snd operators insob e '

moddications to prcWt-alternatisc m srelhng ae spenfm requirements fcr m safe p' ant snutdown shouZ not also shutdown s>sieme are extensise, o ciawoom mstru: Sun, fire fighMg hase to be concerned with hghtmg m the dedicated sys:em that is essential ly a pre w and fae dnlis Sorre area. The small cost differential minimum capabihty safe shutdown train comn~mers felt that these reqmre.nents between 2. hour supply and the and is independamt of those alread) i were more detailed than an>thmg the substantial additional protection existma may be provided.This mmimum Commission has pubbshed with regard afforded by the 8-hour supply does not capabihty is required to maintain the i

to eperator traimng The Commission warrant reducmg this requirement. The process vanables within those saiues '

here po:nts out that most of the Commission has decided to require an 8-predicted for a loss of offsite power.The msestigations of the TMl accident hour batter) power supply in all areas case of loss of offsite power is assumed i

)

identified inadequately trained needed for operation of safe shutdown because fires in certam circumstances operators as an important factor and equipment and m access and egress (e g, electrical distribution system *)

that work is now being done in this routes could cause or be related to such a loss.

i area The fact is not that the training K. Administrative Controls Technical Fire damage to cold shutdown capabihty requirements spelled out here for the fire Basis. The fire protection program uses is limited to damage that can be bngade members are excessive when admmistrative controls for fire repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to proside a

]

compared to training requirements for prevention and prefire planning. The margin in achieving cold shutdown reactor operators, but that fire brigade items listed in this section are generally conditions. Consideration is given to traimng is further along m development, accepted within the fire protection associated cire:uits because most plants j

and training parameters that are community as minimum requirements were not desig ned with this concept in l

essential to a comprehensive program for an effective administration of the fire mind. Should either the alternative or have been identified.

protection program. Controls are placed dedicated capabihty be required to 1

J. Emergency Lighting Technicci on the storage and use of combustible function because of a fire. it must not be Basis Emergency lighting is required in materials to reduce the fire loading in disabled by fire damage to associated all nuclear power plants. Battery-safetygelated areas and on ignition circuits. Also, this capability does not powered hghts with capacities of 1% tc sources to avoid careless operations.

have to meet the single failure critenon 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is usually sufficient for Procedures are used to control actions because it is only one of severallevels emergency egress However, the postfire to be taken by individuals who discover of defense. Seismic Category I criteria is 1

emergency lighting requirements in a a fire and by the fire brigade for the not imposed inause fires that would nuclear power plant are of a different development of preplanned fire fighting require the installation of alternative or kind. The need is for lighting that aids strategies and actual fire fighting dedicated shutdown capability are not i

I the access to equipment and techniques.

seismically induced.

Comment Resoludon Comment Resoludon op ra ed b a t pers n I to ffect safeplant shutdown dunng plant Many commenters stated that this Many of the commenters stated that i

emergscles Because such activities requirement was much too detailed for a this requirement exceeded the scope of may extend over a considerable period regulation. Some stated that the Appendix R by defining alternative f

of time both during and after the fire,it requirements should apply only to those shutdown requirements. They stated is prudent to provide 8-hour battery areas having safe shutdown equipment.

that the time requirements are excessive emergency lighting capability to allow Other commenters stated that a simple and should be dropped. They also sufficient time for normallighting to be statement that administrative contend that this regulation does not restored with a margin for unanticipated procedures should be established to tcke into account the many plant j

events, control the various fire hazards reviews being conducted under the throughout the plant was sufficient, and Systematic Evaluation Program (SEP).

Comment Resolution that the details could be spelled out in a It is generally understood that cold J

Many commenters siated that the regulatory guide or some other similar shutdown is the ultimate safe shutdown requirement for emergency lighting is document.

condition and that, for each fire area, overly restrictive in three specifics: first.

Minor changes have been made in the different means may be used and may that emergency lighting is unnecessary wording of this requirement for be necessary to achieve cold shutdown.

in many of the designated areas; second. clarification.

Because a fire in certain areas at some that the requirement for sealed beam or L Alternative and Dedicated plants would have the capability of fluorescent umts is overly restrictive:

Shutdown Capabihty.

disabling systems required to achieve third. that the requirement for individual TechnicalBasis. In some locations both hot and cold shutdown,it is l

8-hour battery power supply is (such as the cable spreading room) necessary to specify the minimum excessive. Three commenters within operating nuclear power plants, it capability and time requirement for each recommended a 2-hour battery power is not always possible or practicable to condition necessary to achieve safe supply; five commenters recommended a protect redundant safe shutdown shutdown. We agree that evaluations 1

plant-specific power supply; and one systems against adverse effects of fire or being made under the Systematic corr.menter recommended that there be fire suppression activities only through Evaluation Program (SEP) may also call 2

no permanent installation.

the use of fire protection features for alternative or dedicated shutdown i

These suggestions have been accepted because the redundant safe shutdown capabihty for reasons other than fire in part. Lighting units with 8-hour systems in a given fire area are too close protection. For example, seismic, battery supplies are to be provided m all to each other. Alternative shutdown flooding, or emergency core cooling areas needed for operation of safe capability has usually been required to requirements resultmg from the SEP may l

shutdown equipment and in access and be independent of the control room.

require additional modifications. Each egress routes thereto. The reasoning cable spreading room, switchgear rooms licensee should be aware of the status of i

I behind the requirement for an 8-hour.

and cable riser areas because redundant the SEP so that the requirements battery power supply is that there can sy stems in these areas are not resulting from SEP can be effectively I

f be a great deal of other activity durmg a adequately separated. When plant integrated with those relating to fire j

i

=

~66f18 Federal Register M n h m ! Wednesh henter 1R Iwo / Rules and Redatios

~

pn w m m to inc ewn! pehh-required to ensa s.de A awr the nat.onal conserm stardard e i llowrut tS Commsm has deuded capahdm.1ra - of a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> barrxt m for testmg ard ratmg these c ab:e that Me nio+fications required to conjuncima wit h.minita. fire penetration seals Smce the cables complete the fire protec tmn program suppression am! daer tmn capabihty far conduct the heat through the barrier should not be deferred untd the SEP cacn redundant train of safe shutdown and smce the cable msulation is reuew a completed equipmed is based on the follow mg combustible. the acceptance c riterm of N1 Fue Borrmrs-consideratmns Automatic suppression the ASTM Standard E-119 relatirie to TcMnmc/ Hosa The best fire is required to ensi.re prcmpt, effect. e temperature en the unesposed side must protection for redundant trains of safe application of suppressant to a fire that be appropriately modified.

shudow n s> stems is separation by could endanger safe shutdown mmm Rno vuon unpierced fire barriers-walls and' capabiht). The actu ation of an teihng floor assembbes. Decause these automatic fire detection or suppression Some commenters suggested that this barriers are passive fire protectmn system does not occur until sufficient entire section be deleted and replaced features, they are inherently rehaHe smoke or heat has been deuloped by with the following two sentences:

prouded they are properly mstalled and the fire. Therefore. the Commission is

' Penetration seals shall provide the maintamed. Fire barners have been requirmg a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> barrier to ensure thet equivalent protection which is required used successfully for man > years to fire damage wdl be limited to one tram of the fire barrier. Evaluation of the subdnide large potentia! ? ire losses into untd the fire is extmguished penetration sea!s based upon a design smaller, more acceptable nsks. Even fire These requirements have now been review and relevant test data or barriers with openings hn e successfully mcorporated in Section ill G. " Fire quahfication tests may be made." The mterrupted the progress of many fires Protection of Safety Functions; commenters felt that sufficicnt test data pronded the openmgs were properly are available to permit evaluation of

~

• • 1. 1. NN 'N "

design requirements without full. scale protected by fire doors or other acceptable means.

Several commenters made a number mockup testing and that many of the Fire barriers are " rated" for fire of suggestions of an editorial nature.

items spelled out in the regulation. such resistance by bemg esposed to a One suggestion was to add "or unless as the water hose stream test, were too

" standard test fire". This standard test other fire protection features hate been detaded and did not belong in the fire is defined by the Amencan Society provided to ensure equivalent regulation. The Commission has for Testing and Materials in ASTN E-protection" in the first paragraph. where reconsidered this issue and reused the 119. " Standard for Fire Resistante of three-hour rated fire barriers were rule to (a) require the use of Huildmg Materials " Fire barriers are stipulated unless a lower rating was noncombustible materials only in the commonly rated as having a fire justined by the fire hazards analysis.

construction of fire barrier penetration resistance of from 1 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Most The Commission feels that this adds seals. (b) require fire barner penetration

" improved Risk" or "Ihghly Protected nothing in the way of clarification and seals to be qualified by test; and (c)

Risk" (as classified by insurance the suggestion was not adopted. The require such tests to satisfy certain carriers) industrial properties in the second paragraph requires that acceptance critena.

United States require fire barriers to structural steel formmg a part of or O. fire Doors.

have a resistance ratmg of 2 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

supporting any fire barner has e a fire TechnicalBasis. Door openings in fire While a nuclear power plant has a resistance equivalent to that required of walls constitute another breach that low fire load. the potential the barrier. An example was given of must be protected. Fire doors that have consequences of fire are senous.

metallath and plaster covering as being been tested and rated for certain fire Therefore, the Commission has selected one means of providing equivalent exposures are installed to protect these 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> has been as an acceptable protection. Several commenters stated openings. Fire doors frequently fail to minimum fire resistance ratmg for fire that they thought this was too narrow protect the openings in which they are barriers sept ratmg redundant trains for and would be interpreted by some installed because they are not fully safe shutdown systems. This will give people as the only acceptable method closed. Various methods are available to dmple time [or automatic and manual permIlted. binCe the example seemed to bcensees to ensure that fire doors are in fire suppression activities to control any be confusing, a decision has been made proper operating condition and that they potential fire and for safe shutdown to eliminate it. Other comments to the will be closed during a fire. These acti.ities to properly control the reactor.

effect that the requirement was options are listed in Appendix R.

Many operatmg plants, or plants that excessis ely restnctive with regard to C ***"' N###I"###"

are already budt but that are not yet fire barrier penetrations, including fire operatmg. hase both trains of safe doors and their associated frames and Many commenters stated that this shutdow n equipment located in close hardware. and ventilation systems have requirement is too detailed and should proximity and a smgle fire could been acted upon by the staff and the be deleted. Minor editorial changes have damage or destroy the functional requirement, as it had affected these been made m order to more clearly state capability of both redundant trains. If items was deleted.

the requirements.

srecific plant conditions preclude the N. Fire Barrier Cah!e Penetration Seal P. Reactor Coolant Pump Lubricatwn installation of a 3-hour fire barrier to Qualification.

System.

separate the redundant trains. a 1-hour TechnicalBasis. Unpierced fire Technica/ Basis. Each reactor coolant fire barrier and automatic fire barriers offer the best protection for pump motor assemi. typically contams suppression system for each redundant separating redundant trains of safety-140 to 220 gallons of tube oil. Oil leaking tram wdl be considered the equualent related or safe shutdown equipment.

from some portions of the lube od of 3. hour barrier.

However, these barriers must be pierced system may come in contact with if the 1-hour fire barrier and automatic for both control and power cables.

surfaces that are hot enough to ignite the f:re suppression for each redundant These penetrations must be scaled to oil. The resulting fire could be large, and train cannot be prouded because of achieve a degree of fire resistance access to the fire would be delayed plant-specific conditions, alternative or equivalent to that required of the barrier because of the time required to enter the dedicated shutdowns capability wdl be that is pierced. ASTM Standard E-119 is containment. Containent air temperature

1 Federal Register / Vol. 45. No. 225 / Wednesday. November 19, 1980 / Rules and Regulations 76609 would increase. severe loc.ilized pump oil collectior sy stem is covered b)

Ca pa bih t). )Ir: the f re harcas an..lvos f

environments would develop in the area paragraph C.2 because its furiction is for a plant. the equipmerit rehed uprin to l

of the fire, and a large amount of smoke required to protect safety.related perform both functions muv be would be generated. These conditions systems rather than to perform a safety identified for each fire area. It follow s I

could affect operability of safety-related function. Because the failure of the oil that any associated non. safety circuits equipment inside containment.

collectior, system for a seismically in the fire area that could adversely Therefore, an oil collection system is induced oil fire should not prevent a affect the identified shutdown necessary to confine any cil discharged safety related system from performmg equipment by feeding back potentially due to leadkage or failure of the its safety function (Regulatory Guide disabling conditions (e g., hot shorts or lubrication system and to prevent it 1.29. " Seismic Design Classification.'

shorts to ground) to the power supplies from becoming a fire hazard by draining paragraph C.2!. the oil collection system or control circuits of that equipment it to a safe location. These occurrences should be designed, engineered. and must also be evaluated. Of course such could be random or could be seismically installed so that its failure will not lead disabbng conditions must be prevented induced because the existing lube oil to a fire affecting safety related to provide assurance that the identified system piping and oil collection systems equipment as a result of an earthquake.

may not be designed to withstand a The proposed rule permitted tw safe shutdown equipment will function design basis seimic event.

alternatives-an o.1 collection system or as designed. These requirements hat now been incorpore'ed in Section !!I.L 8 Pp s sys e Appendix A to BTP APCSB 9.5-1 hn au omad 1

g

" Alternative and Dedicated Shutdown states that for operating plants.

postulated fires or fire protection s nPression s} stem because Capability."

syotem failures need not be considered unacceptable damage may result to the Comment Resolution concurrent with other plant accidents or safety-related systems from the burning the most severe natural phenomena."

f 11 before the suppression system is hiany commenters stated that this actuated and because the fire water requirement should be deleted because The bas:s for that statement is two fold.

First, nuclear power plants are massive supply system is not designed to many older plard designe did not withstand seismic events. In addition, consider associated circu ts and this is, structures, and essential services are these pumps are located within the therefore. a new design ri quirement.

designed to withstand earthquakes and biological shield inside containment.

The commenters felt that. 'e analysis other natural phenomena. Second. the therefore, timely fire brigade action that will be required to satisfy this hietory of many fires associated with w uld be difficult if the suppression requirement will be both long and recent earthquakes have been system malfuncti ns. Further. if the complicated and the requirement should evaluated. These evaluations showed 8uppression system becomes inoperable therefore be deleted.

that such fires usually are due to failure during peration, a fire watch or patrol The Commission rejected these of piping or tanks of flammable gasses cannot enter the area dunng operation-suggestions for the following reasons.

or liquids such as municipal natural gas diotnbution systems or gasoline storage Comment Resolution

1. Virtually all of the fire protection modifications made to date have been and/or dispensing stations. Where such A number of commenters suggested potential fire hazards exist in nuclear that this section is too detailed and required to correct deficiencies that power plants (e.g., hydrogen for should be substantially modified. This resulted from lack of consideration of generator cooling, or oil fuel for the requirement was changed to delete the certain specific items during initial emergency diesel generator or station option of protecting the reactor coolant design and construction.

opace heating boilers) they are designed pump lubrication system with an 2.The Browns Ferry fire showed the and installed to withstand the damaging automatic fire suppression system. We necessity of divisional separation of the effects of various natural phenomena.

have modified the rule to indicate that associated circuit of the control cables and other special fire protection features the requirement that the oil collection to prevent the disabling of safety are provided as necessary. However, system be designed to provide systems by a single fire. This has been General Design Criterion 2 Design Bases reasonable assurance that it will discussed with licensees during for Protection Against Notural withstand the Safe Shutdown evaluations of alternative and dedicated Phenomena requires that structures.

Earthquske can be met by satisfying shutdown capability and is necessary to systems. and components important to paragraph C.2. of Regulatory Guide 1.29.

ensure that safe shutdown systems will cafety be designed to withstand the

" Seismic Design Classification." as be able to function properly in the event effects of earthquakes without loss of described above.

of f re.

capability to perform their safety Q. Associated Circuits.

function. Regulatory Guide 1.29 TechnicalBasis. When considering

3. The staff considers incomplete any

" Seismic I%ign Classification."

the consequences of a fire in a given fire fire hazard analysis that does not describes an acceptable method for area during the evaluation of safe e nsider the effects of fire damage to circuits that are associated with safe identifying and classifying those shutdown capabilitics of a plant, the features of light. water-cooled nuclear staff must be able to conclude that one shutdown systems.

power plants that should be designed to train of equipment that can be used As indicated above. as a result of the i

withstand the effects of the Safe immediately to bring the reactor to a hot comments received on this issue. it is Shutdown Earthquake. In this guide, shutdown condition remains unaffected unclear that associated circuits have in paragraph C.1 applies to systems that by that fire. The staff must also be able fact been adequately considered by are required to remain functional to to conclude that damage to one train of licensees in their reviews using the ensure heat removal capability; equipment used for achieving cold guidance of Appendix A to BTP APCSB paragraph C.2 applies to systems that do shutdown will be limited so that the 9.5-1. To ensure that the associated not have to remain frunctional for that equipment can be returned to an circuits are considered, all operating purpose. but whose failure could reduce operable condition within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. (See nuclear power plants will be required to the functioning of those systems covered Technical Basis for Section !!!.G.

meet the requirements of Section Ill.G of by paragraph C.1. The reactor coolant

" Protection of Safe Shutdown Appendix R.

.,--,-,---n_--_,-.-

a 76610 Federal Regist-r / Vol. 45. No. 225 / Wednesday. November 19.19m / Rules and Regulations Genen / Q :ments Rem!utw shutdown c apaldts.1 he Commissmn comments retened on the proposed 4 vemd r or"menters (ontended that does not agree n e Mies e that the regah tions. other c ommenters Ce. won n Matmns n.andate that Comnussioni os erd fin protection denntrated a thorough understand ng an ad uda amr3 hearmy he c onducted prograrn inuihing c*nsne planb of du' proposed requirernents.

i pnor to a fmal decismo One mmmenter spnibc hre protahon moMu ations Pursuant to the Atormc Energy Act of labeled the reclation an " order" within that are based on guidance set forth in 1%4. as amended. the Energy the meamng of tbr Admimstrative Hranch Techmtal Position !!TP APCSfl Heorginization Act at 1974. as amended.

Proceduie At t p U S C. 55116)l ( APA) 4 5-1 and its Appendis A and the and Sn tions 552 and 553 of Title 5 of the an f aswrted that 10 CFR 2 2N of the specdic reqmrements of Appendix R to United States Code, notice is hereby Commissmn s regulations. " Order for resols e disputed issues proude unen ihat the following amendments to Mod htatmn of 1.n e nse." apphes to this adequate fire protection Title 19. Chapter 1. Code of Federal One commenter stated that the Regun,tmns. Part 50. are pubbshed as a rulemaLme proremhng T he Commissmn ihsagrees with these amlnguity of the proposed regulation document sub ect to cod:fication t

, omments A 'ruh." is defined m the with reyard to r ritical items requires t A new i 50 48 is added to read as that it be renoticed 'lhe commenter follows-APA 'o mean ' the whoh. or a part of an arrn 3 statement of general or referenced three portions of the particular apphr abiht) and future effect proposed Appendis R e esamples of such ambiguity. They were Section ill.G.

(al h,ach operatmg nuclear power deugned to implement,

. or W Q h have plant shall hase a fire protection plan prescnbe law or pol't>

15 U.S L 551(11) I hr agent y action questioned reviewed these examples, that s.etishes Cntenon a of Appendix A hele is ricarb one that treats simdarly in reference to the first example the to this g. art This fire protection plan situah d in ensees equally and that dh6W Mi dmme the m Mi hre protation prewnbes future conduct or ara raph of Sec tion ill G identibes progrant for the facility, identify the asternative shutdown capabihtv as an vanous positions withm the htensee's reipore unts. For those hcensees who W

e feature and that orgamzation that are responsibde for the base not already provided an equivalent level,! Grc prote( tmn. certam spenfic paragraph 111 G 2 c then idertif +s program. state the authonties that are alternative shutdown tapabihts as a delegated to each of these positions to f re protectmn f"atures are required.

bre protection feature. We do implement those responsibihties. and

\\ annus of these requirements would not agree with this statement The first outhne the plans for fire protectmn. fire apply to approumately 40 faahties. The commenter's charactenzation of the rul" pc

@ d Sect on lil.G identifies detection and suppression capabihty, alternative shutdown capabihty as one and hmitation of fire damage. The plan as an order, ahing with the assertion option in a combmation of fire shall also describe specific features that 10 UH 2.2N mandates a heanng een features for a speafic fire necessary to implement the program before the rule becomes fmalis cea Paragraph Ill.G.3 mdicates when descnbed abose, such as administrative incorrett. Un its f aus that regulation this option should be used.

controls and personnel requirements for lwhich does grant a heanna nght)

In reference to the second example.

fire prevention and manual fire appbes only to Commission orders that the commenter stated that Section III.N suppression activities automctic and mmhfy a hcense *lt does not apply to reqmres a prence diUcrential across manually operated fire detection and requ:rements promulgated through a the test specimen during the testing of suppressmn systems, and the means to rulemaking action 00nducted in fire barrier penetration seals but fails to hmit fire damage to structures, systems, accordance with the requirements of deime the pressure differential. This or components important to safety so apphcable law.

cornment is incorrect. The pressure that the capability to safely shut down Seseral commenters contended that differential called for by the proposed the plant is ensured.'

the environmentalimpact had not been provision was the maximum pressure (b) Appendix R to this part establishes adequately addressed. One commenter.

diUerential that the barrier would fire protection features required to atmu the reqmrements m Section 111 A mperience in the specific plant satsfy Criterion 3 of Appenda A to this of Appendix R for two water supphes installation. In any event, the part with respect to certain generic and two separate redundant sections as requirement for pressure differential issues for nuclear power plants licensed examples of terporements mvolving durmg such testing has been deleted to operate prier to January 1.1979-environmental issues. contended that since only noncombustible matenal is Eu ept for the requirements of Sections the Comnussion relied upon its staff'"

now bemg used for such seals.

!!!.G,1111 and lil O. the provisions of

" unsupported determmation that.

In referente to the third example, the Appendix R to this part shall not be l

pursuant to to CFR i 51.5(d), an commenter stated that Sectmn til Q is applicable to nuclear power plants ensironment;d impact statement-totally lackmg in definitmn. We do not hcensed to operate pnor to January 1.

apprm..l. or neptne declaration is not agree. Footnote ti referentes Regulator) 1979. to the extent that fire protection requned ' 'I he Commissmn has Guide L75 and IEEE Std 3M-1974. The features proposed or implemented by considered Set tion 111 A and has further latter document is a commonly used

~

tonudered the remaimng requirements mdustry standard that defmes

%,,,c tr, pro. 4,mn %,$nt, for nm i,ar pow,r of Appendis H and remains t onvn -:ed aggociated arcuits and provides phmu is wntamed m two NRC duturnents that the regulations are not subst ntive guidance for ensunna that such circuits y"m< h Terbnuat Poait'on Au=iher> P H

and are mssmfu ant f rom the sti adpoint do not compromise the mdependence of of ermronmental impar.t.

the shutdown circuits they are us.,c, n,, pion 3 aa,i,a n,r % 3 in One commenter suggested tha all anociated with.

wa w in plants be regmred to install ded: '.ated Hased on the above examples und our

. pp nain A to Int APGD nt %ehnn review of the other provisions of the fu me N,cne for Nuacar power man's

' n.%hi m he no. t thai i / m4 a ud fwd m proposed nde, we do not I ehese that

""'**dW""'"Id.'t'"~'"**'"'h*'**

e sa.., u,f m < i a hm e n e up, of s a p o n j

"P"*'" "n' undu w annu t.cn of dewen or ronematu before l A c ITE dated August A n

et ify W.wd to me imbed h the oh ff as to require renotiang Moreover. it we m um o rwmu-, a ehr on,

t.wnue' nn rn 2 moi.it lFAph.1 supphed) should be noted that based on other A6 u, Now 4 I

4

. Federal Register / Vol. 45. No. 225 / Wednesday. November 19. 1980 / Rules and llegulations 76611 I

the hee hne been accepted by the after the effectise date of this section determmes upon.* showing by the NRC staff as satisfying the provisions of and Appendix R to this part:

licensee. that there in good cause for Appendis A to Branch Technical (i) the first refueling outage:

extending such date and that the pubhc Petion ItTP APCSil 9 5-1' reflected in (it) another planned outage that lasts health and safety is not adversely i

staff fire protection safety evaluation for at least 60 da> s: or affected by such estenoon. Extensions reports issued prior to the effectise date (iii) an unplanned outage that lasts for of such date shall not exceed the dates of this rule, or to the extent that fire at least 120 days.

determined by paragraphs (c)(1) through protection features were accepted by (4) Those fire protection features that (c)(4) of this section.

' he staff in comprehensive fire require prior NRC approval by (1) Those fire protection features that t

protection safety evaluation reports paragraph (c)(5) of this section. shall be involve revisions of administrative I

issued before Appendix A to Branch implemented within the following controls, manpower changes, and Techmcal Position BTP APCSD 9.5-1 schedule: Dedicated shutdown training shall be implemented within 4 j

waa published in August 1970. With systems-30 months after NRC months after the date of the NRC staff respect to all other fire protection approval: modifications requiring plant Fire Protection Evaluatton Report features covered by Appendix R. all shutdown-before startup after the accepting or requiring such features.

nuclear power plants licensed to operate earliest of the events given in paragraph (2) Those fire protection features pnor to January 1.1979 shall satisfy the (c)(3) commencing 180 days after NRC involving installation of modifications apphcuble requirements of Appendix R approval; modifications not requiring not requiring prmr approval or plant to this part, including specifically the plant shutdown-e months after NRC shutdown shall be implemented within requirements of Sections III.C.111.!. and approval.

12 months after the date of the NRC ggg.o, (5) Licensees shall make any staff Fire Protection Safety Evaluation m difications necessary to comply with Report accepting or requiring such (c) All fire protection modifications these requirements in accordance with features.

require to satisfy the provisions of the above schedule without prior review (3) Those fire protection features.

Appendh R to this part or directly and approval by NRC except for including alternative shutdown affected by such requirements shall be m difications required by Section ll!.G.3 capability, involvmg installation of completed on the following schedule:

of Appendix R to this part. Licensees modifications requiring plant shutdown 1

J (1)Those fire protection features that shall submit plans and schedules for shall be implemented before the startup

]

involve revisions of administrative meeting the provisions of paragraphs after the earliest of the following events controls. manpower changes, and (c)(2). (c)(3). and (c)(4) within 30 days commencing 9 months or more after the i

training, shall be implemented within 30 after the effective date of this section date of the NRC staff Fire Protection t

days after the effective date of this and Appendix R to this part. Licensees Safety Evaluation Report accepting or section and Appendix R to this pert.

shall submit design descriptions of requiring such features:

(2) Those fire protection features that modifications needed to satisfy Section (i) The first refueling outage; involve installation of modifications that Ill.G.3 of Appendix R to this part within (ii) Another planned outage that lasts do not require prior NRC approval or 30 days after the the effective date of for at least 60 days: or plant shutdown shall be implemented this section and Appendix R to this part.

(iii) An unplanned outage that lasts within 9 months after the effective date (6)In the event that a request for for at least 120 days, of this section and Appendix R to this exemption from a requirement to comply (4) Those fire protection features pa rt.

with one or more of the provisions of involving dedicated shutdown capability (3) Those fire protection features.

Appendix R filed within 30 days of the requiring new buildings and systems except for those requiring prior NRC effective date of this rule is based on an shall be implemented within 30 months approval by paragraph (c)(5) of this assertion by the licensee that such of NRC approval. Other modifications section, thct involve installation of required modifications would not requiring NRC approval prior to modifications that do require plant enhance fire protection safety in the installation shall be implemented within shutdown, the need for which is justified facility or that such modifications may 6 months after NRC approval.

in the plans and schedules required by be detrimental to overall facility safety.

(e) Nuclear power plants licensed to the provisions of paragraph (c)(5) of this the schedule requirements of paragraph operate after January 1,19'79. shall section. shall be implemented before (c) shall be tolled until final Commission complete all fire protection starttip after the earliest of the following action on the exemption request upon a modifications needed to satisfy events commencing 180 days or more determination by the Director of Nuclear Criterion 3 of Appendix A to this partin Reactor Regulation that the licensee has accordance with the provisions of their a clant. cation and suidance with respect to provided a sound technical basis for licenses.

perm suble alternatives to satisfy Appendia A to such assertion that warrants further

2. A new Appendix R is added to irrP APCSD w s-1 has been provided in four other staff review of the re uest.

10 CFR Part 50 to read as follows:

pd Appendix R-Fire Protection Program for e

p neary Guidance on infortnation bY R

f i

Nuclear Power Facilities Operating Prior to Needed for pre Protection Es aluahon." dated OctoWr 21. me Safety Evaluation Reports referred to in January 1.1979

. " sample Technnal Specification" dated May paragraph (b) of this section and

12. to*7 supplements to such reports, other than I. Introduction and Scope

• % Wear P:ent Fire Pro'ection Functional features covered by paragraph (c) shall This Appendix applies to licensed nuclear Responsh!.t es Ad.vinistrahve Control and be Completed as soon as practicable but power electric generating stations that were

• '*^~""#*

no later than the completion date P"atmg prior to lanuary 1.1979. except to the extent set forth in parauraph 50 48(b) of o$ 3 79Is currently specified in license conditions se rs A Fee Preect:an Safety Eseluehon Report that or technical specifications for such iI'o[,'$,,Nr','e{iiti, fig,Ttfforth fire has been issued for cath operahng plant states how facility or the date determined by protection features required to satisfy paragraphs (d)(1) through (d)(4) of this Criterion 3 of Appendix A to this part.'

ie if enf ep i t n es e I

resolved when the feuhty sabaface the appropnate seClion, whichever is sooner. unless the reqwrements of Appenda R to th;s pa 1 Director of Nuclear Reactor Regulation

.see footnote 4 2

.. _ _ _ - -.-. ~ -- - --

es J

76612 Federal Register / Vol 45. No. 225 / Wednesday. November 19. 1980 / Rules and Regulations.

Cntenon 3 of Arpendn A to this part program shall estabbsh the hre protectwn D Alternotae or Dnficated Shutdown specahes lhet - 5'ruc.tures. systems and pohcy for the protection of structures.

Capohihty components important to safety shall be systems and components important to safety in areas where the fire protectmn features designed and located to m umaze. consistent at each plant and the procedures. equipment.

cannot ensure safe shutdown capabiht) in i

with other safety requirements. the and personnel required to implement the the esent of a fire m that area alternatwe or probabihty and effect of fires and program at the plant site.

dedicated safe shutdown capahihty shall be esplosions "

The hre protection program shall be under provided.

When considering the effects of fire. those the direction of an mdmdual who has been systems associated with achiesing and delegated authonty commensurate with the

///. Specific Requirements memta.nmg safe shutdown conditions responsibdities of the position and who has A. Water Supphes for Fire Suppression assume mator irnportance to safety because available staff personnel knowledgeable in S3 stems damage to them can lead to core damage both hre protection and naclear safety.

Two separate water supphes shall be resulting from loss of coulant through boiloff.

The fire protection program shall extend provided to furnish necessary water s alume The phrance "important to safety." or the concept of defense-in-debth to fire and pressure to the fire mam loop.

i

" safety-related." wdl be used throughout this protection in fire areas important to safety.

Each supply shall consist of a storage tank.

Appendix R as applymg to all safety with the followmg objectives:

pump. piping. and appropriate isolation and functions The phrase " safe shutdown" will

. to prevent fires from startmg.

control wahes. Two separate redundant be used throughout this Appendix R as

. to detect rapidly, control, and extmguish suctions in one or more intake structures applymg to both hot and cold shutdown promptly those fires that do occur; from a large body of water (river. lake, etc.)

I functions.

. to provide protection for structures, will satisfy the requirement for two separated

}

Because fire may affect safe shutdown systems, and components important to safety water storage tanks.These supplies shall be systems and because the loss of function of so that a fire that is not promptly separated so that a failure of one supply will systems used to mitigate the consequences of extinguished by the fire suppression activities not result in a failure of the other supply.

design basis accidents under postfire will not prevent the safe shutdown of the Each supply of the fire water distnbution conditions does not per se impact pubhc plant.

system shall be capable of providing for a safety, the need to hmat fire damage to D. Fire Hazarris Analyses period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> the maximum expected systems required to achieve and maintain A fire hazards analysis shall be performed water demands as determined by the fire safe shutdown conditions is greater thari the by quahfied fire protection and reactor hazards analysis for safety.related areas or j

need to hmit fire damage to those systems sy stems engmeers to (1) consider potential in other areas that present a fire exposure j

required to mitigate the consequences of situ and transient fire hazards. (2) determine hazard to safety.related areas.

L

. design basis accidents. Three lesels of fire the consequences of fire in any location in When storage tanks are used for combined damage hmits are established accordmg to the plant on the abihty to safely shut down service-water / fire. water uses the mmimum the safety functions of the structure. system, the reactor or or, the soihty to minimize and volume for fire uses shall be ensured by or component:

control the release of radioactivity to the means of dedicated tanks or by some environment; and (3) specify measures for physical means such as a vertical standpipe in o.m.g.

i.

fire prevention, fire detecten, fire for other water service. Administrative se,suncw.

suppression, and fire containment and controls, including locks for tank outlet Hol Snuuonn

. On. tam of.emm.ni n.c.s.g w alternative shutdown Capabihty as required valves, are unacceptable as the only means sca po' ***=a ** *" for each fire area containing structures.

to ensure mmimum water volume.

,"*Q*",",",,

systems, and components important to safety Other water systems used as one of the

. a see o.m.v. tiv a sinw. sa.

in accordance with NRC guidelines and two fire water supplies shall be permanently s

acmano an apoma *. '

regulations.

connected to the fire main system and shall cc.: snuie n-som e

n. ee

=n n maa*

• C Fire Prevention Features be capable of automatic alignment to the fire

$7. 7 "*ca'u2'*

Fire protection features shall meet the main system. Pumps controls, and power e

e an ewoes h.. tius osm.g. awei following general requirements for all fire supplies in these systems shall satisfy the tie amimo no w e inst on. ta*

areas that contcin or present a fire hazard to requirements for the main fire pumps. The

,,"[*"'**

,n,,,'

structures, systems, or components important use of other water systems for fire protes tion

, n,,,

e, to safety.

shall not be incompatible with their functions D.ogn Bass som ten. ce.memene n.cessa4

1. In situ fire hazards shall be identified required for safe plant shutdown. Failure of

'"'"*'9'*""8'**"'***"""

and suitable protection provided.

tha other system shall not degrade the 'are 4

)-

7

2. Transient fire hazards associated with main system

,ng,.

we normal operation. maintenance, repair. or B Sectional / solation Po/res modification activities shall be identified and Sectionalisolation valves such as post gacas, gAa owejQa a gnen eliminated where possible. Those transient indicator valves or key operated valves shall fire hazards that can not be climinated shall be installed in the fire main loop to permit own., w.n,, sues, _,,

,, compon.n ioc a uch be controlled and suitable protection isolation of portions of the fire main loop for 4.o$,n.e,.h ei.d "eAn5".sI"=*o=*N.n'e*c1 owca

=m or w ow, provided.

maintenance or repair without interrupting Thus. a er, evohang on.compon m..mponani een ne se'..nutoo== ***awa'

3. Fire detection systems, portable the entire water supply.

C *,,7.e*,,*" 7.ne.',o*s'n7M.w*e "sd"".**w' oma extinguishers and standpipe and hose C HydrantIsc'atica volves e

stations shall be installed.

Valves shall be installed to permit isolation an men reouno een me, con a

=, to tiem msunaan e ns soc.wo m ew

m. mm

4. Fire barriers or automatic suppression of outside hWrnnts fmm the fire main for The most sinngent fire damage limit shall systems or both shall be installed as maintenance or repair without interrupting apply for those systems that fallinto more necessary to protect redundant systems or the water supply to automatic or manual fire than one category. Redundant systems used components necessary for safe shutdown.

suppression systems in any area containing to mitigate the consequences of other design S. A site fire brigade shall be established.

cr presentmg a fire hazard to safety-related basis acadents but not necessary for safe trained and equipped and shall be on site at or safe shutdown equipment.

shutdown may be lost to a smgle exposure.

all times.

D. Manua/ Fire Suppression fire. Ilowever, protection shall be prosided so

6. Fire detection and suppression systems Standpipe and hose systems shall be that a fire within only one such system will shall be designed, installed. maintamed. and installed so that at least one effective hose not damage the redundant system.

tested by personnel properly quahfied by stream will be able to reach any location that experience and traming in fire protection contains or presents an exposure fire hazard II. Cenem/ Requirements systems.

to structures, systems, or components A. Fire Protection Program

7. Surveillance procedures shall be A fire protection program shall be established to ensure that fire barriers are in, important to safety.

Access to permit effective functioning of estabhshed at each nuclear power plant. The place and that fire suppression systems and the fire brigade shall be provided to all areas components are operable. _

that contain or present an exposure fire

-w

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f Federal Register / Vol. 45. No. 225 / Wednesday, November 19. 1980 / Rules and Regulations 76613 harard to structures sye' ems or components hour ranna In addition f,re detectors and an Institute for Occupational Safety and uportant to safety, automatic fire suppressmn system shall be Health-approval formerly p+en try the U.S Standpipe and hose stations sha.1 be insile installed in the f.re eres Bureau of Mines) shall be prouded for fire PWR contamments and BWR conte!nments inside noninerted conta:nments one of the brigade. damage control, and control room that are r et inerted Standptpe and hose fire protection means specif:ed abou or one personnel. At least to masks shal1 be ststions inside containment may be of the followmg fire protection rneans shall available for fire brigade personnel. Control connected to a high quehty water supply of be provided room personnel may be furnished breathing sufhcient quantity and pressure other than

d. Separation of cables and equ:pment and att by a manifold system piped from a 4

the fire mein loop if plant-specific festates associated non safety circuits of redundant storase reservoirif practical Serv ce or rated present extending the fire rnain sepply inside trains by a hortrontal distance of more than operating life shall be a m:nimum nf one. half containment. For BWR drywells, standpipe 20 feet with no intervening combustibles or hour for the self-contained units and hose stations shall be placed outside the fire barards:

At least two extra air bottles shall be dry well with adequate lengths of hose to

e. Installation of fire detectors and an 1 :sted on site for each self-contained reach any location inside the dry well with automatic fire suppression system in the fire breathing unit. In addition. an onsue s hour an effective hose stream.

area; or supply of reserve air shall be provided and E. Hydrostatic Hose Tests

f. Separation of cables and equipment and arranged to permit quick and complete Fire Nose shall be hydrostatically tested at associated non-safety circuits of redundant replenishment of exhausted supply att bottles a pressure of 300 pel or 50 pel above trains by a noncombustible radi.r.: energy as they are returned. If compressors are used 2

maximum fire main operating pressure, shield as a source of breathing air, only units whichever is greater. Hose stored in outside

3. Alternative or dedicated shutdown approved for breathing str shall be used.

hose houses shall be tested annually. Intertor capabihty and its associated circuits?

compressors shall be operable assumina a standpipe hose shall be tested every three independent of cables. systems or loss of offsite power. Special care must be years components in the area. room or rone under taken to locate the compressor in areas free F Autornatic Are Detection consideration. shall be provided:

of dust and contaminants.

Automatic fire detection systems shall be

a. Where the protection of systems whose I. Are Brigade Trainins installed in all areas of the plant that contain function is required for hot shutdown does The fire bngade trainirqt program shall or present an exposure fire hazard to safe not settsfy the requirement of paragraph G.2 ensure that the capability to fight potential shutdown or safety-related systems or of this section cr fires is established and maintained. The components These fire detection systems

b. Where redundant trains of systems program shall consist of an initial classroom shall be capable of operating with or wi hout required for hot shutdown located in the instruction program followed by periodic offette power.

name fire area may be subject to damage classroom instruction, fire fighting pract;ce.

. ire suppression activities or from tne and fire drills:

G Are Pietection ofSofe Shutdan Capabihty rupture or inadvertent operation of fire

1. /nstruchon

1. Fire protection features shall be provided suppression systems.

a. The initial classroom instruction shall In addition. fire detection and a fixed fire include:

for structures. systems, and components important to safe shutdown.These features suppression system shall be installed in the (1) Indoctrination of the plant fire fighting shall be capable of limiting fire damage so area. room. or zone under consideration.

plan with specific identification of each that:

H. Are Brigade individual's responsibihties.

a. One train of systems necessary to A site fire brigade trained and equipped for (2) Identification of the type and location of achieve and maintain hot shutdown fire fighting shall be established to ensure fire hazards and associated types of fires that conditions from either the control room or adequate manual fire fighting capability for could occur in the plant.

emergency control station (s)is free of fire all areas of the plant containing structures.

(3) ne toxic and corrosive charactenstics damage; and systems. or components important to safety.

of expected products of combustion.

b. Systems necessary to achieve and The fire brigade shall be at least five (4) Identification of the location of fire maintain cold shutdown from either the members on each shift. The brigade leader fighting equipment for each fire area and control room or emergency control station (s) and at least two brigade members shall have familiarization with the layout of the plant, can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

sufficient training in or knowledge of plant including access and egress routes to each

2. Except as provided for paragraph G.3 of safety-related systems to understand the area.

this section, where cables or equipment, effects of fire and fire suppressants on safe (5) The proper use of available fire fighting includmg associated non-safety circuits that shutdown capability. The quahfication of fire equipment and the correct method of flahting could prevent operation or cause brigade members shallinclude an annual each type of fire.De types of fires covered maloperation due to hot shorts, open circuits, physical examination to determine their should include fires in energized electrical or shorts to ground. or redundant trains of ability to perform stenuous fire fighting equipment. fires in cables and cable trays.

act!vities. The shift supervisor shil not be a hydrogen fires, fires involving fleramable and systems necessary to achieve and maintain bot shutdown conditions are located withi s member of the fire brigade. De origade combustible liquids or hazardous process leader shall be competent to assess the chemicals. fires resu.' ting from construction or the same fire area outside of primary p tential safety consequences of a fire and modifications (welding), and record file fires.

containment. one of the following means of a v se C ntr Ir m personnel. Such (e) The proper use of communication, ensuring that one of the redundant trains is c mpetence by the brigade leader may be lighting. ventilation, and emergency breathing free of fire damage sh,, be provided; evidenced by possession of an operator s equipment.

a. Separation of cables and equipment and license r equivalent knowledge of plant (7) The proper method for fighting fires associated non-safety circuits of redundant safety-related systems.

Inside buildings and confined spaces.

trains by a hre berner having a 3. hour rating.

The minimum equipment provided for the (8) The direction and coordination of the brigade shall consist of personal protective fire fighting activities (fire brigade leaders p in9 a f

arrier hall e equipment such as turnout coats, boots.

only)' Detailed review of fire fighting protected to provide fire resistance g!oses. hard hats. emergency communications (g}

equivalent to that required of the barner-equipment portable lights, portable strategies and procedures.

b. Seperation of cables and equipment and ventilation equipment. and portab!e (10) Raview of the latest plant essociated non safety circuits of redundant extinguishers. Self-contained breathing modifications and corresponding changes in trains by a hortrontal distance of more than apparatus using full face posittve-pressure fire fighting plans' 20 feet with no intervening combustible or masks approved by NIOSH (National fire harards. In addition, fire detectors and an Nots.-Items (9) and (10) may be deleted automatic fire suppression system shall be from the training of no more than two of the

' by installed in the fire area; or

' Pl :

non-operations personnel who may be rero 1 n r locat 3 or mo f

ns

'O O* b 8* b

c. Enclosure of cable and equipment and

,y,, ems: dedicated shutdown capabihty is provided associated non-safety circuits of one by instalhng new structures and systems for the

b. The instruction shall be provided by redundant train in a fire barrier having a 1*

funchon of post-fire shutdown.

qualified individuals who are knowledgeable.

r--.

.m.

766M Federal Reghter ' W 45. No m / Wednesd4 Notember m M Rub and Reguhmom ved i i f We h eadr and se;m t on r:,u rment and w c' aJJtona! f.re t ro'et t on m +e e s renem s

c n p. s

~ < u +. + r p:a nt

. q gmert and f,rr ' gMmg Crvegn i a A pe< rdare

.+t a s Qble 2 Am'.swn' d ec h t r gode mem! 4 r s 5,

i.our

+e a. ofisntwr s ur<estt use 4

s F

inew; edge of ha or her rdr n te $re IaI'e ete rat u erm icroren,'we ang Nmm u

I? s i'i -

- pr 4.ded to a3 h e f#t.rg Mrateg for th area assripd to l' a n* 4 2 ?en t.razir.g i i SEterms

.m! f.re bng4 Je le mb rs

< o*iam the hre /me ssn ent of the t.r gade m etat o A srp4 rate p errmt e.A be tssued br.a

-a m:.s N

, Me. J meet:rgs snah be brid r enter s conformance we estabbshed er e.n h aren w he re won is to be d me !!

i t

e. su e s. rs a rr.:r5 for all br:gh piant fire fightmg pro < edres and use ef bre w.d i ont u+ s oser rr. ore than one shdt the wn.N s*

res ew i h oes m the hre f:g" r.g e qaipment mcNd,ng sed < or.tered prmt i%:1 be ul:d for not more than 24 pn tectwn prmari i,3 uter wherts as emergency bream ;ng apparatus tc - den the plant is operat:ng m f ar the n n *m rs c ommunication eqapment. and s er"Jatm deatum of a part:cular 105 Cr.rg p; ant e perdn rebesni r tr+nmg sesoons eaS rw ; ment. to the event prn Sc4l !r shutdow n.

b. h,od to repeat the classroom mstna t.on W The omulated use of f:re f@rg 6 Centrol the rrmm al from t%,*rea of WI ran tur a:1 bngaJe members our a two equ:pm nt required to cepe w:th t e 6.*aa m wave dehns urap oil spa or omer A

p s

3 e..r p. m ! 1 N se sesm: ns m.n be and ty pe of fire se:wed for the M Tre abt:bles resmtmg from the wars at taity m rrer.1 wab 'he regu!ar planned stea and type of fire thosen fr w dnli imr eiaki) fuBowirq t empietiv, ofthe Tre' ras shou!d d:ffer from thme used m the preuous actam er at the ena of exh worn shift drdi so th41 brede members are tramed m w h heur c omes first

/h Pro

..e sessmns shall be ht>;d fx e ac h f.shting fires m s anous plant area Tb i Wnta.n the penodic housekee pmg sr..f' 'ce t4 rode on the proper method of 5,tmen se:erted shMd sutuiate the s:ze m>per t ors to ensure contmoed comphance fighwg the s aneus types of fires tha* tou:d and arrangement of a hre that ceald with these admn:stratae contro;s m ur m a nm ! ear power plant These reawnaW oa ur m the area seie<.ted n Control the use of spenfic combust:b;es sessmr s shaU prmide bngade members with ahowmg for f:re desekpment d;e to the tm:e

n safeg.rebted areas AM wood umi m esr.ers m e :n a.tua! fire ntmguishment and reqmred to respond 'o ot tam equ,pment. and saf* t) related areas darms mamtenant e.

r 6

use vf emergeng breathms apparatun urgamre for the fire assummg loss cf mcdifa ;stion. or ref acimg operatmns 1such as b r s renuous t enditwns ent ountered m autumatu 5.ppressmn capabh la)-down bWin or uoffo:J rgi shau be

' e f a5%: Ibese practne sessmns shall be 141 Assessraent of bngade leaderi neated w tn a f'ame retardant Equip *r.ent or tre s e d at ! cast om e per sear for each fire d:rertu n of the fire f ghtmg effort as to suppDes Isar b as nrw f ach shy ped.n bngde n.mbe-thoroushness accurat), and ef'ertaimess unt eated combusnMe packing conta:rers J&%

4 RecoMs mas be unpacked m safets.related areas if Ere bncade dr.H shalt be performed m Inda adual records of tra.nmg prmided to reymred far s ahd opera's.s reasons a

• e L Lnt s 3 that ine fire bngesde can practice each f:re bngade member. mcludmg dnu floweser. a!! tumbusnble matena!* sha!! he as a oam tritques shall be ma:ntamed far at least 3 remmed from the area immediateh fouowmg b Dnus snu be performed at regular

> cars to ensure that each member recenes the unpackmg. Sach trans;ent combusoble eteruls not to eu ced 3 months for each trammg in all parts cf the tramma program matenal. unless stored *n appres ed srdt fire br:gade Each fire bngade member These records of tramma shall be asadable i enta:ners. shall r.ot be lef t unattended shouU partopate in eat h dnlL but must for NRC review. Re'ra:ning or bruaJened danna lunch breaks shift changes or other parnapate m at least two dr6s per Scar.

tramma for f:re fightma with.n buddmus shall simdar penuds Ioose combushb e packmg A suffiuent number of these drills. but not be sobeduled for all those bngade members matenal such as wood or paper euchier. or iesa than one for each shift fire bngade per whose performance records show pol >cthslene sheetmg shall be p! aced m H dr sha'l be unannounced to determme the defiaenoes metal containers with tight-f;ttmg i. elf-closmg f rr fighting readmess of the plant fire j Emercr LigN rs metal c os ers bngadt bocade leader, and fire protectmn Emergency hghtma unds with at least an &

9 Control actions tu be taken by an sutems and equipment Persons planning hour ba"ery power supply shall be prosided mdmdual discosenng a fire. for esample.

end authonzmg an unannounted dnll shall in all areas r eeded for operation of safe notification of control room, attempt to ensure that the respondmg shift fire bngade shutdown equipment and in access and estmguish fire. and actuation ef local fire members are not anare that a dnllis bems egress routes thereto.

suppressmn s) stems planned untd it is begun Unannounced dnlis A. Admmstratise Controls

10. Control actions to be taken by the shau rmt be scheduled closer than four Ad'.mistrative controls shall be control room operatur to determine the need w ee k s estabbshed to mmimae fire hazards m areas for hngade ass: stance upon report of a fire or At least one dnll per Scar shall be contamme structures. nstems and receipt of alarm on control room annunciator performed on a bad shif t" for each shif t fire comp,nents irnpartant to safety These panel for esample. announnnu locat.on of bngade r ontrols shall estabbsh procedures to-fire ou r PA system, sound:ng fire alarrrs r The dnUs sbail be preplanned to 1 Gcsern the handhre and I mitatien of the and not:fynx the shif t supersisor and the fire ce ibbsh the trammg olyectises of the dnu use of ordmary combustible matenals bngade leader of the type. uze. ard locatmn ard shall be e ntiqued to determme how wed combusnhie and flammable gases and of the fire the tom.ng ob et ta es bas e been met.

hqutd3. high effinency parta alate air and 11 Control actions to be taken by the fire t

l'nannoun< ed dnns shali be planned and (nan oal fdters. dry ion eschange reWns. or bngade after net;ficatmn bs the control room r rmwed bs r embers of the management other combust.ble supphes m safey related operator of a fire. for exampte. asserrbbng m Wf resp.msb'e fer p' ant safen and fee areas a designated location. rerening direr.nons prw tion h rformanw dr fiaenues of a f,re

2. Prehht the store of combust:bles m from the fire bnsade leadt.. and dw haryng bryade or of mdmdual fire bngade merrbers safeturelated areas or estabbsh des:gnated spenfit fire fightmg respons:bdines mclud;ng Cl be rer edred bs sihedelmg addit:enal storage areas with appropnate f.re sbrimn and transportation of fire f:shnng ng for the bruade or members p rotec non equi; ment to f;re locanon. selection of a

( nuo.f.o tory drd perfonnance sho? be 1 Gose n the bamtbng cf and hmit protectae equipment. operatmg mstructrons f? owed by a repeat d-dl withm 30 da3s transient fee loads such as combust:ble and for use of fire suppression systems. and use d N 1 sear mtersals. a random!s me!ected flammabie 1: quids wood and plast c of preplanned strategies for f.chtirts fires in anar.m ed ed!

• hah be cntiqued b) products. or other combusuble matenals in speaf:c areas o AfvJ ndmdu.ds Me;,endent of the buddmas contam.ng safetyvela'ed n stems 12 Defme the strategies for fightmg fires in lu en3ee s staff A wps of the wntien report or eqmpment dunna au phases of operanne all sa'ety related areas and areas presentmg fnm 5.xh mJaiduais sha!l be asadaNe for and especians dunna mamtenance a hazard to safet) related equipment. These

.wC res ww mod fication. or ref actne operations strate >nes shah des'gnate:

hre huards m each area coured by the e 16.3 eau as a nen: mum mcluJe the 4 Desgnate the ans;te staff member a

W.ow n c respons.ble for the mpiant f;re protettwn speafa prefire plans I! hsewnt of f.re abrm efin taenen rn +w of proposed work actmties to idertify b hre estmsuishants best swted for f ue re% red to not.fs and assemble f:re potent, : transtent fire harards and sperdy c ontroihna the fires anociated with the f:re

i Federal Register / Vol. 45. No. 225 / Wednesdab November 19, 1980 / Rules and Regulations 76615 N en W t ae nearest toutier coul ant lesel aonse the tm of the core f r separation and barriers between trays and rse eenit aban**

BWRs and be within the lesel mdication in conduits contamme associated circuits of one Wt Arce d:rcetien from wh:ch to the pressunrer for PWRs-safe shi.tdown dmsion and trays and t

W fce m estr; area m v.ew of tne c Tne reactor heat removal function shall conduits centainmg associated circuits or e or hecnon. & cess nal:na>s stairs be capable of achievmg and mamtaming safe shutdown cables from the redundant c ; wo mat av mos 1:sel) to be tree of deca) heat remos at division. or the isolation of these assoc 6ated b and the best statio or elesatwn fer d The process monitonng function shall be circuits from the safe shutdown equipment fes the fire All acti s ind caress routes capable n! prosidmg direct readings of the shall be such that a postulated fire involvmg l

u ms A e Lc ked door should tw procen sanables necessary to perform and associated circuits will not prevent safe stwif.caih ident:f.ed m he procedure with control the abose functions.

shutdow n>

o

% apprupnate ;recautions and methods for

e. The npportmg functions shall be M Are Bamer Cable Penetrotron Seal access spenfied capable of providmg the process coohng.

Quahhcotion d Plant ssstems that shou;d be manased to lubncation. etc., necessary to permit the Penetration seal designs shall utilire only reduce the damage potential danng a local operation of the equipment used for safe noncombustible matenals and shall be fire and the location oflocal and remote shutdown functions.

qualified by tests that are comparable to tests contrais for such management (e p.. an)

3. The shutdown capability for specific fire used to rate fire barners. The acceptance b>draul:c or electncal systems in the tone areas may be unique for each such area. of it entens for the test shallinclude:

<oscred by the specific fire fighting procedure may be one unique combination of systems L The cable fire barner penetration seal that could mceense the harards in the area for all such areas. In either case, the has withstood the fire endurance test without because of oserpressurire;on or electrical alternatise shutdown capabihty shall be passage of flame or ignition of cables on the harardst mdependent of the specific fire area (s) and unexposed side for a period of time e Vital heat-sensitive system components shall accommodate postfire conditions where equivalent to the fire resistance rating that need to be kept cool while fightir'g a offsite power is availab!e and where offsite required of the barrier.

local fire. Part:cularly harardous power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />

2. The temperature levels recorded for the combustibles that need coolmg should be Procedures shall be in effect to implement unexposed side are analyzed and des:anated this capability.

demonstrate that the masimum temperature j

f Organization of fire fightmg br gades and 4 If the capability to achieve and maintam is sufficiently below the cable insulation a

the assignrnent of special duties accordmg to cold shutdown will not be available because ignition temperature. and job title so that all fire fightmg functions are of fire damage. the equipment and systems

3. The fire barrier penetration seat remains covered by any comp!*te shift personnel compnsing the means to achieve and intact and does not allow projection of water complement These duties mclude command maintain the hot standby or hot shutdown beyond the unexposed surface dunng the control of the bnaade, transportmg fire condition shall be capable of maintaining hose stream test.

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suppression and support equipment to the fire such conditions until cold shutdown can be N. Fue Doors nenes, applying the extinguishant to the fire.

achieved. If such equipment and systems will Fire doors shall be self-closing or provided communication with the control room. and not be capable of being powered by both with closing mechanisms and shall be coordination with outside fire departments.

onsite and offsite electric power systems inspected semiannually to verify that A

g Potential radiolog: cal and tosic hazards because of fire damage, an independent automatic hold-open release, and closing m fire tones onsite power system shall be provided. The mechanisms and latches are operable.

h Ventilation system operation that number of operating shift personnel.

One of the following measures shall be ensures desired plant air distnbution when exclusive of fire brigade members, required provided to ensure they will protect the the ventilation flow is modified for fire to operate such equipmer and systems shall opening as required in case of fire; contamment or smoke clearing operations.

be on site at all times.

1. Fire doors shall be kept closed and

i. Operations requiring control room and

5. Equipment and systems comprising the electrically supervised at a continuously shift engmeer coordmation or authorization.

means to achiese and maintain cold manned location; j instructions for plant operators and shutdown conditions shall not be damaged

2. Fire doors shall be locked closed and general plant personnel dunng fire.

by fire; or the fire damage to such equipment inspected weekly to verify that the doors are L. Alternotne end Dedroted Shutdown and systems shall be limited so that the in the closed position; Copabihty systems can be made operable and cold

3. Fire doors shall be provided with

1. Alternative or dedicated shutdown shutdown achieved within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> automatic holdepen and release mechanisms capabihty provided for a specific fire area Materials for such repairs shall be readily and inspected daily to venfy that doorways shall be able to achieve and mamtatn available on site and procedures shall be in are free of bstructions; or subentical reactivity conditions m the effect to implement such repairs. If such

4. Fire doors shall be kept closed and reactor maintain reactor coolant inventory equipment and systems used prior to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inspected daily to venfy that they are in the achieve and maintam hot standb> '

after the fire will not be capable of bemg cl sed position.

conditions for a PWR (hot shutdown ifor a powered by both onsite and offsite electric The fire brigade leader shall have ready BWR) and achieve cold shutdown power systems because of fire damage, an access to keys for any locked fire doors.

conditions withm 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and mamtain cold mdependnet onsite power system shall be Areas protected by automatic total flooding shutdown conditions thereafter. Dunng the provided. Equipment and systems used after gas suppression systems shall have postfire shutdown, the reactor coolant system 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may be powered by offsite power electncally supervised self-closmg fire doors i

process vanables shall be maintamed withm only.

or shall satisfy option 1 above.

a o#edion Systein for Reodor those predicted for a loss of normal a.c.

6. Shutdown systems in %.led to ensure power. and the fission product boundary postfire shutdown capaNity need not be coolant pump shall be mtegnty shall not be affected. i e., there shall designed to meet seismt. Category I criteria, be no fuel clad damane. rupture or any single failure criteria, or over design basis equipped with an oil collection system if the contamment is not inerted dunna normal pnmar) coolant boundary, or rupture of the accident cnteria, except where required for operation. The oil collection system shall be cc itamment boundary.

other reasons, e g., because of interface with so designed, engineered, and installed that 2 The performance goals for the shutdown or impact on existing safety systems, or failure will not lead to fire dunng normal or i

functions shall be:

because of adverse valve actions due to fire design basis accident conditions and that a The reactmty control function shall be damage.

capable of achievmg and mamtaimng cold

7. The safe shutdown equipment and shutdow n reactinty conditions.

systems for each fire area shall be known to An aueptable method of complytna with this b The reactor coolant makeup function be isolated from associated non safety

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d shall be tapable of mamtammg the reactor circuits in the fire area so that hot shorts.

Std 3844974 (Section 4 5) where trays from open circuits. or shorts to ground in the redundant safety dmsions are so protected that i As defmed in the Standard Techracal associated circuits will not prevent operation postulated fires affect trays from only one safety Specifwe' ions of the safe shutdown equipment.ne dmenon.

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76616 Federal Register / Vol. 45. No. 225 / Wednesde. Nm ember 19. 1980 Ruln and Regulations

m. re n te oonal !c.mur an< r that the sptem win withcan.1 the %fe Shutdown f iritq Mr hh w;;euson antents shall be capable of tolloclang lube oil f rorn el potential pressurized and unpressurized leakage sites in the reactor c oolant pump luhe oil systems Irakage shall be r.ollectcJ and drained to a sented doned container that can hold the ent:re tube od notem insentor) A flame arrester is reymred in the sent if the flash point characteristics of the o:1 present the hazard of fire f6hbu k. trakage points to be protected shallinclude I:fr pump and piping.

overflow hnes, lube od cooler, oil fill and drain bnes and plugs, flanged connections on od lines, and lube oil reservoirs where such features cust on the reactor coolant pumps The drain hne shall be large enough to accommodate the largest potential cil leak (Sec.161b. lu L 83-703, tA Stat 948. sec. 201. Pub L 93418. M Stat 1242 (42 U S C.

220Mbl. 241))

Dated at Washington. D C.. this 17th day of November 1980.

For the Nuclear Regulatory Commission.

Samuel I. Chilk.

Secretary of the Commission.

py Ike arwas17s Fded 11-ike a 43 em]

BILLING Coot Ts904il-48 s

• See Regulatory Guide 13 "Scismic Design Claseda.ation" paragraph C 2

SUMMARY

OF STAFF REQUIREMENTS TO RESOLVE OPEN ITEMS MILLSTONE UNIT 2 DOCKET NO. 50-336 3.2.1 Cable Spreadina Area In the Fire Protection Safety Evaluatier. Report it.was our concern that an adequate level of fire protection has not been provided for the redundant safety-related cables in the cable spreading area.

By letters dated May 29, 1980 and October 9, 1979, the licensee proposed the following modifications for the cable spreading room:

1.

An automatic wet pipe sprinkler system installed throughout the room.

2.

An existing manually operated deluge system.

3..

Two additional hose stations.

4.

A third entrance into the room to allow more flexibility for manual fire fighting.

5.

Fire dampers 6.

Fire barriers to separate redundant from non-essential cables.

The. licensee has not demonstrated that adequate protection features have been provided for cables and equipment of redundant systems important to. achieving safe shutdown conditions to ensure that at least one means of achieving such conditions survives postulated fires.

To meet our fire protection guidelines, in addition to the licensee's proposed modifications, alternate shutdown capability,should be provided when safe shutdown cannot be ensured by barriers and detection and suppression systems becau'se of the exposure of redundant safe shutdown equipment, cabling, or components in a single fire area, to an exposure fire, or fire suppression activities, or rupture or inadequate operation of fire suppression systems.

l To meet Section III, Paragraph G.of the new Appendix R to 10 CFR Part 50, the licensee should provide an alternate shutdown capability inde-pendent of this area. The alternate shutdown system should meet the require-ments of Section III, Paragraph L of Appendix R to 10 CFR Part 50.

3.2.2 Protection of Redundant Cable Trays In the Fire Protection Safety Evaluation Report, it is our concern a fire may cause the loss of redundnat safe shutdown systems located in the auxiliary building.

An evaluation of cable routing in the auxiliary building was conducted by the licensee, and the results were provided by letter dated July 31, 1979. A l

site visit 'to specifically examine those areas in question was conducted 31, 1979. As a result of this visit, modifications,such as on August fire-rated barriers, cable tray covers, and automatic sprinkler protection documented by letter dated October 9,1979 and clarified by letter were dated November 21, 1979.

The licensee has not demonstrated that adequate protection features have been provided for cables and equipment of redundant systems important to achieving safe shutdown conditions to ensure that at least one means of achieving such conditions survives postulated fires in the following areas:

1.

Auxiliary Building Zone IA, Column F.8/H.2 and 16.6/17.2, elevation -45.

2.

Auxiliary Building Zone A-24, Columns F.8/H.2 and 17.4 elevation 14'-6".

3.

Auxiliary Building Zone A-14, Column F.8/H.2 and 18.1.

To meet our fire protection guidelines, alternate shutdown capability should be provided when safe shutdown cannot be ensured by barriers and detection and suppression systems because of the exposure of redundant safe shutdown equipment, cabling, or components in a single fire area, to an exposure fire, or fire suppression activities, or rupture or inadequate operation of fire suppression systems.

To meet Section III, Paragraph G of the n'ew Appendix R to 10 CFR Part 50 the licensee should provide an alternate shutdowncapability' independent of The alternate shutdown system should meet the requirements of this area.

Section III, Paragraph L of Appendix R to 10 CFR Part 50.

The licensee should provide a primary coolant pump lube oil collection system which meetsSection III, Paragraph 0 of Appendix R to 10 CFR Part 50.

6.0 Administrative Controls - Fire Briaade In the Millstone 2 Fire Protection Safety Evaluation Report, it was our concern that the licensee's fire brigade was not sized, drilled, and trained sufficiently to provide assurance that the manual fire suppression capability would be adequate.

By letter doted September 27, 1979, the licensee provided a document entitled

" Justification For Three-Man Fire Brigade." The licensee concludes that a three-man fire brigade can adequately extinguish or control any fire to assure safe plant. operation, achieve safe shutdown, and minimize radioactive Further, by letter dated July 11, 1979, the release to the environment.

licensee proposed to provide annual classroom training and quarterly drills.

However, the licensee claims that ensuring all brigade members participate in one drill per quarter is not necessary to ensure an effective fire brigade response.

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In our letter dated September 7, 1979, we prnvided the licensee our report entitled " Evaluation of Minimum Fire Brigade Shif t Size" (dated

)

June 8, 1978) in which we conclude all operating plant. sites should have an onsite fire brigade shif t complement of at least five trained persons.

In addition, we provided our position regarding fire brigaue training and drills which conclude that classroom training and drills should be held every 3 months for all fire brigade members.

The fire brigade size and training program should meet the requirements of Section III, Paragraphs H and I of the new Appendix R to 10 CFR part 50.

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